5% or 20% housing supply buffer? - Public forum - Planning Advisory Service (PAS)

Perhaps the best way is to look at how PINS are seeing things e.g. see the inspectors comments on this issue in the examination of the Taunton Deane core strategy. My reading of things is that it depends on whether the plan has been postively prepared (i.e. plans for growth) and where it has, PINS may be more generous. Having said that, it may depend on the individual inspector.

Am echoing Peter's question - how are local authorities determining whether to apply a 5% or 20% buffer to their 5 year housing land supply?

Ian, How are you thinking of calculating it? I do think the point about the plan being positively prepared may well help the Inspectors' view. I would suggest that you will want to consider delivery over an economic cycle. To put it another way, go back 10 years. 2003-2007 lead us up to the 'boom' and the years after that are the 'bust'. I appreciate that you may have to factor in RS figures, and these may or may not have been geared up to a 'going for growth' strategy, exacerbating under-delivery where a more 'practical' figure has been achieved all along. I don't think this is the case in Gedling though? You can then see if you have delivered in, say 6 of the 10 years, or fewer. If you can't demonstrate meeting the targets over at least this many years, I'd say your under-delivery is persistent. There has been a lot of debate on the ordinary meaning of 'persistent' and I don't want to rehearse that again here. Feel free to disagree, of course! I would add that this seems a reasonable approach to me, given that almost no-one will have delivered against targets in the depths of the recession. Any thoughts? Adam

Thanks Adam for your comments :-) most helpful

Whatever the ins and outs, I think it's most prudent to assume persistence and the 20% unless you've got very strong grounds to demonstrate otherwise. The reality is that it's effectively a six year supply in five years.

Absolutely Dan, it is all about the evidence (for everything in your plans!). Either you can demonstrate you've been delivering or you can't. The 'very strong grounds' are your completion figures, pure and simple. But you do need to go back a reasonable amount of time. Everyone knows the situation in recent years. That's why I suggested an economic cycle (or 10 years for what has been happening). Yes, if you are looking at 'plus 20%' you are basically having to show you have another years' worth of supply that is deliverable now. Anyone have a recent examination where this came up? There will be quite a few Inspector's reports to look at now. Did someone say 'plan, monitor, manage'?

Adam A recent Secretary of State decision on a site at Tetbury accepted the inspector's reasoning that a 20% buffer should relate to 5 years prior to the inquiry on the basis that supply looked forward 5 years. Not very scientific but I guess it has some logic. On the evidence available the Inspector concluded that Cotswold DC had a persistent under delivery of housing and so imposed the 20% buffer to a housing requirement that she had to conclude upon as there was no agreed basis to calculate it. The appeal ref is APP/F1610/A/11/2165778